AS9110C Clause 8.5.1.2 Validation and Control of Special Processes for Repair Station

M

Mark_N

#1
Hi everybody!

Does anyone have any experience with 9110 and special processes in Repair Station? We are the repair station that maintains Boeing and Airbus aircraft up to and insluding D-Check (heavy maintenance). During this maintenance we can use repair procedures that are considered as special processes but these proceses are very "light" if compare with a manufacture.
For example:
- we use a soldering for the repair of landing lights to change the bulb,
- we use a heat treatment for rivets during repairs of aircraft structure,
- we perform a lot of NDT inspections,
- we strip a paint and re-paint aircraft and components,
- we crimp connectors during defect rectification related to wirings,
- we weld some cracks on thrust reverses doors.

All of these works we perform iaw approved maintenance data from TC holders - AMM, SRM, CMM etc.

I feel some doubts that our repair station shall do the same things as manufacturer, regarding the special processes.

I have checked existing manuals:
- Airbus has Process and Material Specification (PMS) that estables requirement for the proceses in whole, and SRM (structure repair manual) that provides detail instructions for particular work.
- Boeing has Standard Overhaul Practices Manual that provides detailed instructions for the processes and SRM (structure repair manual) that provides detail instructions for particular work.

For example, Heat Treatment: SRM describes the themperature ranges, time and tests for verification but nothing about furnace parameters for heat treatment. These parameters and quality requirement for the process in whole I found in PMS.

Airbus know well and use NADCAP for their suppliers-manufacturer but when I tried to ask Airbus about their policy related to the special processes (throuhg techrequest service) in the maintence - nobody could understand what does special process mean. EASA does not use the term "Special process", they use the term "Specialized works"
Thechnical manuals (AMM, SRM etc) do not use the term "Special process" also.

So, when we perform the works that can be considered as the special processes, we always do it strongly in compliance with approved instructions developed by TC Holder (Airbus or Boeing). We also do not fabricate any parts during repair.

My question - What procedures we have to develop additionally to be in compliance with AS9110 requirements?

Situation is very funny as all our maintenance managers know nothing about special processes and this repeats in all Repair stations that I know.
 
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M

Mark_N

#2
Re: AS9110C Clause 8.5.1.2 Validation and Control of Special Processes for Repair Sta

I really need advice :(
 

howste

Thaumaturge
Super Moderator
#4
Re: AS9110C Clause 8.5.1.2 Validation and Control of Special Processes for Repair Sta

My question - What procedures we have to develop additionally to be in compliance with AS9110 requirements?
Here are the requirements that need to be met:
AS9110 Rev C said:
8.5.1 Control of Production and Service Provision

The organization shall implement production and service provision under controlled conditions.

Controlled conditions shall include, as applicable... f. the validation, and periodic revalidation, of the ability to achieve planned results of the processes for production and service provision, where the resulting output cannot be verified by subsequent monitoring or measurement;

NOTE: These processes can be referred to as special processes (see 8.5.1.2) complying with the requirements of the applicable technical data issued by the type certificate holder or acceptable to the competent authority.

8.5.1.2 Validation and Control of Special Processes

For processes where the resulting output cannot be verified by subsequent monitoring or measurement, the organization shall establish arrangements for these processes including, as applicable:
a. definition of criteria for the review and approval of the processes;
b. determination of conditions to maintain the approval;
c. approval of facilities and equipment;
d. qualification of persons;
e. use of specific methods and procedures for implementation and monitoring the processes;
f. requirements for documented information to be retained.
The short answer is, if all of these requirements are met by using the tech data provided by the Type Certificate Holder, then you don't need more procedures. If only some of these requirements are addressed in the TC Holder's documents, then you will need to define, document, and implement your own requirements to cover the missing ones.

For example, let's say you have a process with a document from the TC Holder that specifies criteria for the review and approval of the process, conditions to maintain approval, methods and procedures for implementing and monitoring the process, and required records. You would then need to determine and define requirements for approval of facilities and equipment and personnel qualification. You will need to look at each process and ensure that each process for each TC Holder has all bases covered.

An alternative would be to develop your own comprehensive procedures that meet all TC Holder requirements. These would need to be updated whenever TC Holder requirements are updated. It would be a lot of work, but would avoid confusion if you have different customers with different requirements for the same type of process.
 
M

Mark_N

#6
Re: AS9110C Clause 8.5.1.2 Validation and Control of Special Processes for Repair Sta

Here are the requirements that need to be met:


The short answer is, if all of these requirements are met by using the tech data provided by the Type Certificate Holder, then you don't need more procedures. If only some of these requirements are addressed in the TC Holder's documents, then you will need to define, document, and implement your own requirements to cover the missing ones.

For example, let's say you have a process with a document from the TC Holder that specifies criteria for the review and approval of the process, conditions to maintain approval, methods and procedures for implementing and monitoring the process, and required records. You would then need to determine and define requirements for approval of facilities and equipment and personnel qualification. You will need to look at each process and ensure that each process for each TC Holder has all bases covered.

An alternative would be to develop your own comprehensive procedures that meet all TC Holder requirements. These would need to be updated whenever TC Holder requirements are updated. It would be a lot of work, but would avoid confusion if you have different customers with different requirements for the same type of process.
:thanks: I agree with you.

I had idea to get the list of special processes that are performed in maintenance from TH Holder. I asked Airbus to provide us such list (if they have it) or explain their policy regarding special processes in maintenance. However, they didn't understand what I ask. I know that Airbus has his special Rep in NADCAP and I asked Airbus to send this request to people/department who are responsible for special processes in Airbus - no reaction. I know, that some TC Holders have such list of special processes for old aircraft that still have old "Overhaul" philisophy.

I was hoping that if Airbus provided us with such list, it would greatly reduce the number of processes that we will consider as special.
 
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